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5.11 Tactical California Transparency in Supply Chains Act Statement

The California Transparency in Supply Chains Act of 2010 (the “Act”) requires certain retailers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their supply chains.

The purpose of the Act is to increase public awareness on a company’s efforts to eliminate slavery and human trafficking, allowing consumers to make an informed decision on the products they purchase and the companies they choose to support.

5.11 is committed to conducting business in a lawful and ethical manner and we place the same expectation on our suppliers. We believe that workers have the right to freely choose where they work and be treated with dignity and respect. We will only do business with suppliers who share this belief. Our efforts to ensure that slavery and human trafficking are not used in the production of our products include the following:

Supplier Certifications:

By signing our Supplier Agreement, our vendors certify that their factories comply with the terms and conditions of the Agreement which includes prohibiting the use of forced labor including labor obtained through slavery or human trafficking. 5.11 has also created a Vendor Code of Conduct, in line with international labor standards and laws, which prohibits the use of all forms of forced labor.

Verification and Evaluation of our Supply Chain:

5.11 requires all direct suppliers to complete a Supplier Questionnaire disclosing information on all factories who produce 5.11 products. As a condition of doing business, direct suppliers’ factories must agree to a third-party audit to verify compliance with our Vendor Code of Conduct. In addition, whenever possible, our Sourcing teams conduct factory walkthroughs to evaluate their capability to produce 5.11 products. Part of this evaluation includes observing the working conditions in the factory and notifying our social compliance team of any non-compliance issues found during the walkthrough.

Third Party Audits:

Our direct supplier factories are required to undergo an audit to verify compliance with our Vendor Code of Conduct. Audits are conducted on an annual basis by our nominated third-party firms and cover all areas of the factory, including residential facilities, if applicable. Employee Interviews are also conducted in groups as well as individuals. Factory Management are not present during these interviews so workers can feel comfortable to freely comment on the working conditions at the factory. Auditors also review employee documents for age, pay, work hours, residency, etc.

Accountability:

5.11 will not tolerate violations involving any form of forced labor, slavery or human trafficking. Vendors or factories alleged to be in violation of this policy will be fully investigated and corrective actions will be taken, which may include the termination of the business relationship.

Training:

Our Social Compliance team regularly attends industry trainings and seminars to stay abreast of the risks and signs of human trafficking and slavery in global supply chains. We are also evaluating the development of a training program for our sourcing teams to increase awareness of modern day slavery and human trafficking in global supply chains and to encourage them to report any human rights concerns observed during their factory visits.